HomeMy WebLinkAbout01-7185 Our File No. 149222
'~TTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C.
BY: Eric M. Berman, Esquire, I.D. 83698
BY: Ron Z. Opher, Esquire, I.D. 57507
198 Allendale Road, Suite 306
King of Prussia, PA 19406
(610) 265-7720
DISCOVER BANK
c/o ERIC M. BERMAN, P.C. :
198 Allendale Road, Suite 306 :
King of Prussia, PA 19406 :
:
VS. :
:
GRETCHEN HAAS
:
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
TRID~L DIVISION
CIVIL ACTION
Term
No -
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by attorney and filing
in writing with the court your defenses or objections to the claims
set forth against you. You are warned that if you fail to do so the
case may proceed without you and a judgment may be entered against you
by the court without further notice for any money claimed in this
complaint or for any other claim or relief required by the plaintiff.
You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW OR FIND OUT WHERE YOU CAN GET LEGAL HELP.
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plaza al partir de la fecha de la demanda y la
notificacion. Hace falta asentar una comparencia escrita o en persona
o con un abagado y entregar a la corte en forma escrita sus defensas
o sus objeciones a las demandas en contra de su persona. Sea avisado
que si usted no se defiende, la corte tomara medidas y puede continuar
la demanda en contra suya sin previo aviso o notificacion. A demas la
la corte puede decidir a favor del demandante y requiere que usted
compla con todas las provisiones de esta demanda. Usted puede perder
dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATEMENTE. SI NO TIENE ABOGA
O SO NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
LAWYER REFERRAL SERVICE, COUNTY OF CUMBERLAND BAR ASSOCIATION
Address: 2 LIBERTY AVE., CARLISLE, PA 17013 Tel.: 800-990-9108
Our File No. 149222
ATTORNEYS FOR PLAINTIFF
ERIC M. BERMAN, P.C.
BY: Eric M. Berman, Esquire, I.D. 83698
BY: Ron Z. Opher, Esquire, I.D. 57505
198 ALLENDALE ROAD, SUITE 306
KING OF PRUSSIA, PA 19406
(610) 265-7720
DISCOVER BANK
c/o ERIC M. BERMAN, P.C.
198 Allendale Road, Suite 306
King of Prussia, PA 19406
VS.
GRETCHEN HAAS
:
COMPLAINT
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
CIVIL ACTION
Term
1. Plaintiff, DISCOVER BANK ,
is a DELAWARE BUSINESS TRUST
licensed to do business in the Commonwealth of Pennsylvania with its
place of business at P.O. BOX 8003, HILLIARD, OH 43026.
2. The Defendant(s), GRETCHEN HAAS
resides at 1323 CONCORD RD , MECHANICSBURG, PA 17050-1957.
3. There is due from the Defendant(s) the sum of $6,906.17 for
credit extended by Plaintiff to Defendant(s), acct. no. 6011002440640209,
and which such credit was drawn and used by the Defendant(s).
Defendant(s) is in default for failure to make payments for such use.
4. The Plaintiff has made demand upon the Defendant(s) for payment
of monies in the sum of $6,906.17 advanced to Defendant(s) through
Defendant(s) use of the above-referenced credit account, but Defendant(s)
has failed and refused to pay the said sum or any part thereof.
5. Ail applicable credits, if any, have been duly applied to
Defendant(s) credit account.
WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $6,906.17
plus interest, attorneys fees and costs which are justly due and
owing from the Defendant(s) to the Plaintiff.
Dated: NOVEMBER 16, 2001
SPACE-AQ
BY:ERIC M~P.C.
ERIC M. BERMAN, ESQUIRE
BY:
RON Z. OPHER, Esquire
Attorneys for Plaintiff
VERIFICATION
RON Z. OPHER, ESQUIRE, being duly sworn according to law, deposes
and says that he is of Counsel to the Law Firm of Eric M. Berman,
P.C., and/or ERIC M. BERMAN, ESQUIRE, being duly sworn according
to law, deposes and says that he is the Principal attorney of Eric M.
Berman, P.C., attorneys for the Plaintiff, and as said attorney, he
is authorized to take this verification on its behalf, and that the
facts in the Complaint as set forth therein are true and correct to
the best of his knowledge, information and belief.
I verify that the statements made in the within instrument are
true and correct. I understand that false statements are subject
to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn
falsifications to authorities.
ERIC M. BERMAN, ESQUIRE
Dated: NOVEMBER 16, 2001
RON Z. OPHER, ESQUIRE
SPACE-AQ
ATTORNEY: B~P.~JAN
6011002440640209
BALANCE:
CARDMEMBER(S):
$6906.17
GRETCHEN HAAS
STATE OF OHIO
COUNTY OF FRANKIN
G. Rogers, personally appeared before me, this day and after being duly
sworn, according to law, upon her oath and says:
THIS person is a Legal Placement Account Manager for
DISCOVER FINANCIAL S~RVICES INC.,the servicing agent of DISCOVER BANK,
an FDIC insured Delaware State Bank.
THAT, in their capacity as Legal Placement Account Manager, Affiant has control
over and access to records regarding the account of this debtor; further that
the Affiant has personally inspected said account and statements regarding the
balance due on said account. These Records are kept in the normal course of
business.
THAT the undersigned Affiant being duly sworn deposes and says that the policies
and procedures of DISCOVER BANK and it's servicing agent, DISCOVER
FINANCIAL SERVICES, INC. are in accordance with applicable federal and state
consumer and credit laws.
THAT the annexed statement of account, in favor of DISCOVER BANK, is
a true and correct statement and there is now due and owing to DISCOVER BANK,
the sum over and above all legal set-offs. 'Attached' hereto as
exhibit A is a copy of the terms of the account which we forwarded with the
charge card to the Cardmember(s).
THAT to the best of Affiant's knowledge and belief the defendant is employed in
civilan life and by reason thereof is not engaged in the military service of the
United States and is a resident of the State and of the Country in which this
action has been filed.
THAT this affidavit is made on the basis of Affiant's personal knowledge and in
support of Plaintiff's suit on account against said Debtor.
Sworn and Subscribed before me
this 8TH day of MARCH, 2001
"'"' BETH A. OAKLEY
~'~ Notary Public
'. j In and for the State of Ohio
)/ My Commission Expires
· " Feb, 15, 2005
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-07185 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
HAAS GRETCHEN
SHANNON SUNDAY , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
HAAS GRETCHEN the
DEFENDANT , at 1421:00 HOURS, on the 9th day of January , 2002
at 1323 CONCORD ROAD
MECHANICSBURG, PA 17050-1957 by handing to
GRETCHEN HAAS
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.28
Affidavit .00
Surcharge 10.00
.00
36.28
Sworn and Subscribed to before
me this /~ day of
~ ~2~L A.D.
~t~rothonotary · , -
So Answers:
R. Thomas Kline
01/10/2002
ERIC BERMAN
Deputy Sheriff
ERIC M. BERMAN, P.C.
BY: Ron Z. Opher, Esquire
Attorney for Plaintiff
Attorney #57507
198 Allendale Rd., Suite 306
King of Prussia, PA 19406
(610) 265-7720
Discover Bank
Plaintiff
Gretchen Haas
1323 Concord Rd.
Mechanicsburg, PA17050.7957
De~ndant
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PA
CIVIL ACTION - LAW
NO. 01-7185 CIVIL TERM
PRAECIPE TO WITHDRAW COMPLAINT WITH~)UT PREJUDIc~ ,;
TO THE PROTHONOTARY:
Kindly mark the ' · ·
PREJUDICE. Complmnt in the above-captioned matter WITHDRAWN WITHOUT
DATED: January 10, 2002
BY: ~
Ron Z. Opher, Esquire
Attorney for Plaintiff